A. Overview Everhart Financial Group, Inc., doing business as Everhart Advisors, is a corporation located in and formed under the laws of the State of Ohio, and is a registered investment adviser with the Securities and Exchange Commission (“SEC”). Everhart Advisors was founded in 1995. Our main office is at 535 Metro Place South, Dublin, Ohio 43017. We also have offices at 2 Prestige Place, Miamisburg, Ohio 45315 and 12140 Carissa Commerce Court, Suite 104, Fort Myers, Florida 33966. Each advisory client of Everhart Advisors is assigned one or more investment adviser representative who is appropriately licensed and qualified to provide investment advisory services tailored to each client’s situation. We provide advisory services to retirement benefit plans (e.g. 401(k) plans) as well as wealth management services to individuals and entities. B.1. Advisory Services for Retirement Plans Everhart Advisors’ client in this Item 4.B.1 is an employer that desires to provide its employees with a retirement benefit plan. Everhart Advisors provides consulting services to qualified and nonqualified retirement plan sponsors, including investment advice, fiduciary due diligence services, employee education, asset allocation, vendor research and analysis, and plan design guidance. We also serve as an advisor to multiple and pooled employer plans. Investment Advice for Retirement Plans Everhart Advisors provides research and analysis of investment products and fiduciary due diligence services. Our goal is to establish a thorough investment due diligence process that is consistently employed in the selection and ongoing monitoring of investment options and is compliant with applicable fiduciary obligations and the client’s investment policy statement. Everhart Advisors typically provides plan fiduciaries with a periodic report that scores the investment options in each asset class considering several criteria, including past performance, management and cost. Based on the results of this periodic analysis Everhart Advisors may recommend changes to the investments offered to plan participants. Everhart Advisors may either draft an investment policy statement for the plan sponsor’s review and consideration or evaluate the existing investment policy statement and provide appropriate recommendations. Employee Plan and Investment Education Everhart Advisors may provide employee enrollment, re-enrollment, and investment education support. The goal of this process is to help plan participants make informed choices about the plan and investment allocation under the investment education guidelines set forth by the U.S. Department of Labor. Education meetings are offered on an annual, semi-annual, quarterly, or as requested basis. These meetings may be held in a group or individual setting and may be conducted on-site or via remote conferencing. Everhart Advisors will not actively solicit plan participants to become advisory clients (with the exception of senior executives and business owners outside the education process), but we may provide advisory services to plan participants upon request. In that event, the plan participant will enter into an Asset Management Agreement with us and pay us a fee in accordance with that Agreement. Our providing advisory services to plan participants results in a conflict of interest, for example, if we advise a plan participant to invest monies in another investment vehicle that could be invested in the plan. We are usually paid more to manage assets outside the plan. We believe this conflict is mitigated by the value to plan sponsors of allowing plan participants to receive the benefit of individually tailored advisory services, which outweighs the marginal benefit to plan sponsors of a larger plan. We further believe it is frequently in the plan participant’s best interest to receive individually tailored advisory services. Plan participants are never obligated to become advisory clients of our firm, and we are not obligated to accept a plan participant as an advisory client. Plan Asset Allocation Models Everhart Advisors may create, monitor, adjust, and rebalance asset allocation models (“Models”) for use by the plan sponsor as an investment tool provided to plan participants to assist them in making asset allocation decisions for their investment portfolios (i.e. between equity and fixed income). Models are designed to meet different investment objectives based on risk level. The goal is to assist plan participants meet their investment objectives by allocating their account balances among a range of investment options to construct diversified portfolios that appropriately span the risk/return spectrum. Plan participants alone bear the risk of investment results from the options and asset allocation they select. Vendor Research and Analysis Everhart Advisors may assist plan sponsors with the selection of service providers for their plan based on research and analysis of several potential vendors. The vendor review process typically includes an evaluation of administrative, recordkeeping, compliance, and employee communication services, administrative and investment-related fees, and where appropriate, an investment review that incorporates an analysis similar to the investment due diligence process described above. Plan Design Guidance For clients newly implementing a retirement benefit plan Everhart Advisors offers to advise them on the design and pertinent features of the new plan. For clients with existing plans we offer plan reviews that entail an analysis of several design features which may include eligibility requirements, vesting, forfeitures, employer contribution formulas, entry and re-entry dates, and auto-enrollment and escalation provisions. Absent a specific agreement to the contrary, Everhart Advisors does not perform and does not receive compensation for “settlor functions.” Any services provided by Everhart Advisors deemed to be “settlor functions” are merely incidental to the services we provide as the designated consulting representative. General Plan Consulting Services Everhart Advisors generally assigns a Servicing Consultant who is responsible to address ongoing questions, concerns, and issues raised by the plan sponsor. Services typically include plan pricing and contract negotiation between the incumbent provider and the plan sponsor, recommendations of specific service and product enhancements, facilitation of solutions to service, administrative, and recordkeeping issues, plan compliance assistance and guidance, and ongoing problem solving. Everhart Advisors typically provides a "help email" address, and "1-800" phone consultation assistance for plan participants. 404(c) Checklist Everhart Advisors typically provides plan sponsors with a checklist of the latest industry accepted standards for 404(c) compliance and works with the plan sponsor to facilitate completion of the checklist. The plan sponsor is ultimately responsible for addressing and verifying compliance with each item. Fiduciary Role under ERISA When we serve as a consultant to a retirement plan Everhart Advisors is a fiduciary under either Section 3(21)(A)(ii) or Sections 3(38)(A) and (B)(i) of the Employee Retirement Income Security Act of 1974, as amended (ERISA). Everhart Advisors is a co-fiduciary with the plan sponsor. The agreement between Everhart Advisors and the plan sponsor will specify the nature of our fiduciary role. Where Everhart Advisors is a 3(21) fiduciary, the retirement plan sponsor is responsible to select the investment options available under the plan. Where we are a 3(38) fiduciary, we are responsible to select the available investment options. B.2. Advisory Services for Individuals The client in this Item 4.B.2 is an individual or entity seeking investment or wealth management advice. Everhart Advisors’ advisory services are tailored to individual clients in light of their specific circumstances. Everhart Advisors seeks to understand a client’s financial resources, obligations, objectives and risk tolerance through an initial interview process, periodic review meetings and a review of any pertinent documents provided by the client. We may also provide advice regarding:
• Capital needs; debt and cash flow planning
• Risk management and insurance needs
• Tax planning considerations
• College funding
• Retirement planning
• Business succession planning
• Estate planning considerations
• Special needs (adult dependent needs, education needs, disability needs, etc.) While our advice is tailored to each client, Everhart Advisors generally adheres to a buy and hold investment strategy as we believe in the underlying strength and long-term viability of the market economy. Volatility is inherent in the market system, but we believe it is counterproductive to chase short-term performance. Therefore, we do not try to time or outsmart the market. We invest prudently and encourage discipline. We generally prefer low expenses, stability, and appropriate diversification considering the client’s risk tolerance and time horizon. Everhart Advisors creates model portfolios which are recommended in appropriate cases, depending upon a client’s specific circumstances. Our model portfolios are not tailored to individual clients. Recommended investments may include mutual funds, exchange traded funds (ETFs), indexed funds, individual stocks, fixed and variable annuities, single premium immediate annuities and fixed income vehicles including bonds, and when appropriate, alternative investments such as private investment funds, limited partnerships, limited liability companies, real estate investment trusts (REITs) and private equity transactions. A client’s specific circumstances and objectives may compel a deviation from our general philosophy. Clients may place reasonable restrictions on the types of securities purchased on their behalf by notifying Everhart Advisors in writing. As part of our services we periodically review client portfolios on an ongoing basis to determine if any changes are necessary. Consistent with our investment philosophy, absent a material change in financial or personal circumstances a client’s asset allocation may remain largely unchanged for extended periods of time. We believe our role includes fostering client education and discipline, which facilitates good investing behaviors, which in turn promotes better outcomes. Accordingly, our fees are billed even during periods of account inactivity. Everhart Advisors devises asset allocation strategies based on information provided by the client. Clients are thus responsible to promptly notify Everhart Advisors in writing of changes to their financial status, objectives or risk tolerance. Client Education Everhart Advisors seeks to educate clients about financial markets, our guiding investment philosophy, as well as good investing behavior and discipline. We provide this education via the client on-boarding process, periodic reviews, client newsletters, workshops and periodic posts to our website and social media sites. B.3. Miscellaneous 1. Cash Balance Plans We provide consulting services relating to the creation and administration of cash balance plans. We may advise

on plan design, investment allocation, testing and compliance, and vendor selection. Our fee for such services is typically calculated as a percentage of the value of the assets in the plan as set forth in our written client agreement. 2. Family Office Services In limited circumstances we provide some clients expanded services more typical of a family office. Such services vary widely by client and are frequently “one-off” occurrences. Not all clients receive such expanded services. Depending on the circumstances we may provide the service free of charge, or we may charge a one-time fee, or an ongoing fee which will vary by client. 3. Tax Consulting and Bookkeeping Services Everhart Advisors provides tax consulting services, including tax return preparation for individuals and entities, tax compliance and transactional advice. We also provide bookkeeping services. Tax consulting services are provided by certified public accountants employed or retained by Everhart Advisors. Our investment advisor representatives are not tax professionals. Clients who utilize our tax consulting or bookkeeping services pay fees separate from and in addition to our investment advisory fees. This presents a potential conflict of interest insofar as we are incented to recommend clients utilize our tax- related or bookkeeping services in order to earn additional fees. Clients are never required to utilize such services and are free to retain tax professionals of their own choosing. 4. Consultation Agreements with Other Firms Everhart Advisors’ may enter into agreements with other professionals, including law, accounting or other investment advisory firms to provide consulting services regarding retirement plan clients. Everhart Advisors will be paid a mutually agreeable fee for each consulting engagement, which will be specified in the engagement agreement executed prior to the initiation of any consultation services. 5. Other Services In addition to providing investment advice, Everhart Advisors’ investment advisor representatives, in their capacity as insurance agents may sell insurance products to clients. Clients are not obligated to buy insurance through Everhart Advisors, but when they choose to do so Everhart Advisors will receive commission compensation in addition to our advisory fees. Clients may separately engage us to provide advice about business succession planning. Such clients will typically pay an hourly or flat fee for these services. Some clients may request advice regarding a discreet aspect of their investments or finances. For these clients Everhart Advisors may offer services in a modular format or consulting services limited to those specific areas of concern. Such clients may be charged differently than our typical advisory clients, including a flat, recurring annual fee. Our advisors are occasionally retained to speak at conferences or workshops. We typically receive a flat fee for such appearances. 6. Retirement Accounts and Rollovers Clients seeking to rollover ERISA or IRA accounts to new or existing accounts managed by Everhart Advisors should be aware they may lose certain advantages, suffer adverse tax consequences, and/or incur higher costs. These situations present a conflict of interest as we are incented to recommend a rollover in order to earn a fee on those assets. Everhart Advisors attempts to address this conflict of interest by educating the client regarding the costs and benefits of any rollover, educating our investment advisor representatives on the issues presented and always making recommendations in the client’s best interest. To that end we have a rollover process designed to ensure that i) the client is adequately informed; and ii) the rollover is in their best interest. Clients should be aware they have options and are under no obligation to rollover assets to accounts managed by us. Clients may incur lower costs by leaving the money where it is or rolling it over to accounts not managed by us. Clients are encouraged to understand the potential risks and costs of any rollover and to address any questions or concerns with their investment advisor representative or Everhart Advisor’s Chief Compliance Officer. Everhart Advisors is a fiduciary under ERISA and/or the Internal Revenue Code when it recommends a rollover of funds to an account managed by us. Accordingly, all such recommendations must be in the client’s best interest. When we provide advice regarding any retirement account we are fiduciaries under ERISA and/or the Internal Revenue Code. The way we make money creates conflicts with your interests. As fiduciaries, we are required to place your interests ahead of our own. We must: meet a professional standard of care in making recommendations to clients; not mislead clients; follow policies and procedures designed to ensure that our advice is in clients’ best interest; charge reasonable fees; and notify clients about existing conflicts of interest. If any client has any question or concern about our advice or conduct, they should contact Everhart Advisors’ Chief Compliance Officer. 7. Private Investment Funds In appropriate cases Everhart Advisors will provide investment advice regarding private investment funds and other non-publicly traded investments such as REITs, limited partnerships and limited liability companies. On a non-discretionary basis, we may recommend that certain qualified clients consider an investment in a private investment fund. If the client determines to make such investment, it will be considered an “asset under management” and its value included in the calculation of our advisory fee. Our fee will be based on the latest value provided by the fund sponsor. No client is obligated to consider or make an investment in a private investment fund. Only clients who meet certain criteria (which are subject to change at our discretion) are eligible to make such investments under our management, however, in appropriate cases we may make exceptions to such criteria. Private investment funds involve various risks, including without limitation, illiquidity, lack of transparency and the complete loss of principal. Clients must carefully review and fully understand the offering documents and the attendant risks prior to making such an investment. 8. Professional Referrals Everhart Advisors may coordinate with other professionals retained by clients, such as accountants, insurance agents and attorneys. Upon request we may refer clients to other professionals. In either case, Clients should be aware that fees incurred with other professionals in connection with this process are not included as part of the advisory fees charged by Everhart Advisors, and we are not responsible for, nor do we guarantee their advice or work product. Everhart Advisors does not provide legal advice and its investment advisor representatives are not tax professionals. In some cases, the professionals to whom we refer clients are also clients of the firm. In other instances, the professionals to whom we refer clients may refer clients to us. This presents a conflict of interest insofar as Everhart Advisors has an incentive to make referrals to benefit us rather than the client. We seek to address this conflict by always placing our clients’ interest first and referring to professionals we believe are well suited to meet the client’s particular need. Clients are not obligated to retain professionals recommended by us and must conduct their own due diligence to determine whether to hire a particular professional. We do not enter into agreements that obligate us to make or trade referrals. 9. Dimensional Fund Advisors Mutual Funds Everhart Advisors may recommend, or clients may hold Dimensional Fund Advisors (“DFA”) mutual funds. These funds are only available through registered investment advisers approved by DFA. Thus, if a client terminates our services the ability to transfer DFA funds to another advisor may be restricted. 10. Client Information In performing our services Everhart Advisors utilizes information provided by clients. We are not required to verify any information received from clients or professionals engaged by clients, and we are expressly authorized to rely on such information. It is our clients’ responsibility to promptly notify us in writing of any change in financial condition or investment objectives to allow us to review and revise our recommendations as needed. 11. Investment Risk Investing in securities involves the risk of loss of the entire principal amount invested and any gains. Any investment strategy recommended by us may lead to a loss. Clients should not invest unless they are able to bear this risk. Different investments involve varying degrees of risk, and it may not be assumed that any specific investment or investment strategy will be profitable or equal any specific (past or projected) performance level. It is impossible to accurately predict which sectors of the market or asset classes will earn more favorable returns for a given period. In addition, investing carries with it opportunity risk. Past performance may not be indicative of future results. 12. Borrowing Against Investment Assets Clients may choose to borrow money against investment assets under our management. Clients will typically pay a fee to the lender and interest on the amount borrowed. There are risks involved in taking such loans. The lender will have recourse against the pledged investment assets in the event of default, or if the value of the assets falls below a certain threshold. Clients must be careful to fully understand and accept the risks involved before taking any such loan and Everhart Advisors cannot be responsible or liable for any adverse consequences. Additionally, we continue to earn our fee on the value of the pledged assets. If any loan proceeds are deposited in an account managed by us, we will earn a correspondingly higher advisory fee. 13. Courtesy/Accommodation Accounts Everhart Advisors may agree, at our discretion, to manage assets on behalf of an individual or entity as a courtesy. In that case we will not charge a fee for our services, and we may not be held liable in connection with such relationship or for services provided for which we did not charge a fee. D. Termination of Agreement Clients who wish to terminate their agreement with Everhart Advisors may do so by notifying us in writing. If services are terminated within 5 business days from the date the agreement is signed, services will be terminated without cost. After the initial 5 business days the client may be responsible to pay fees for the number of days services were provided prior to receipt of the notice of termination. Everhart Advisors may terminate its agreement with a client upon written notice to them. In the event of termination by either party, any prepaid but unearned fees will be reimbursed to the client based on the date of termination. E. Assets Under Management As of December 2023, Everhart Advisors had approximately $1,400,000,000 in discretionary assets under management and approximately $43,600,000 in nondiscretionary assets under management. These amounts do not reflect assets under advisement held in retirement plans for which Everhart Advisors is the plan consultant.